Archive/File: people/i/irving.david/libel.suit/transcripts/day010.18
Last-Modified: 2000/07/20
MR JUSTICE GRAY: Well, I mean, that is the point that I
have just put to you, Mr Irving. Can you tell us what the
answer is?
MR IRVING: I appreciate that Mr Rampton would prefer to
conduct my cross-examination for me.
MR JUSTICE GRAY: Just answer my question.
MR IRVING: I will come clean and say precisely what points
I am going for. Professor van Pelt has suggested that,
because in one of the drawings there is a requirement for
the vorwarmung or prewarming of the mortuary. This has a
sinister connotation. Am I right, Professor?
A. This is not there was drawing. This is there was letter,
so I did not in any of my discussion, when you asked me
about drawings right now, include that particular
document. I said I was specifically talking about
drawings.
Q. While we are on that document, can you tell me how
important is that letter and how much reliance would you
place on that as being halfway to the smoking gun?
A. I do not know if I should answer this right now since
another question was posed.
MR JUSTICE GRAY: Is your answer because I am going to go back,
that it is part of the convergent evidence? Is that how
you put it?
. P-153
A. It is an important part of convergent evidence, yes.
MR JUSTICE GRAY: Let's go back, Mr Irving. I am going to
insist that we get this clear and then we know where we
are going.
MR IRVING: May I return to the prewarming later on, my Lord?
MR JUSTICE GRAY: Of course you can return to it later on.
What is your position going to be? Supposing that the
evidence satisfies me that there is reason to believe that
this was intended to be there was gas chamber and not an
air raid shelter, is that something you accept or dispute?
MR IRVING: It should be, with respect, my Lord, relatively
easy for the witness to say there are two or three
items,
as he in fact said, which were to him, taken in
conjunction with each other, adequate evidence that
there
was a sinister purpose.
MR JUSTICE GRAY: That is as may be, but I would like an
answer
to my question because I think you must come clean as
to
your position.
MR IRVING: I do not think I am equivocating. My position
on
this particular room is that it was never used in
there
was gas chamber sense, in the sense described by the
eyewitnesses because of course the lack of holes
proves
that the eyewitnesses have lied.
MR JUSTICE GRAY: That is getting close to an answer but it
is
not quite an answer. Are you accepting it was a gas
. P-154
chamber in the sense that it had the facility for gas
to
be inserted by whatever means, but contending that
humans
were never killed by gas in that chamber?
MR IRVING: Certainly on one occasion it was referred to as
a
Vergasungskeller and also referred to as a
sonderkeller, a
special cellar or special basement. That I also
accept.
What I do not accept is that it was going to be used
for
the mass killing of human beings by gas. This is a
very
clear statement. What I do postulate is that it was
also
simultaneously being held in prospect and even
converted
for use as an underground air raid shelter, being one
of
the very few subterranean buildings on the site in the
event that mass attacks in this part of Poland also
began,
given the proximity of the IG Farben works.
MR JUSTICE GRAY: I am sure I missed it, but was part of
that
answer that yes, you do accept that it was there was
gas
chamber and that you accept that it was on occasion
used
for killing human beings?
MR IRVING: I accepted it was referred to as there was gas
chamber, my Lord, which is not quite the same thing
and
there are documents ----
MR JUSTICE GRAY: Are you accepting it was in fact there
was
gas chamber?
MR IRVING: That I have not seen evidence for.
MR JUSTICE GRAY: So you are not accepting that?
MR IRVING: I am not accepting that part of the statement
. P-155
because I have not seen any evidence that bears that
part
of the statement out. I have seen evidence that it
was
referred to by the German authorities as there was
Vergasungskeller, there was room for gassing in.
MR JUSTICE GRAY: But you still do not accept that it was
in
fact there was gas chamber? Is that the position?
MR IRVING: That is precisely my position, my Lord.
MR JUSTICE GRAY: Then we go through the drawings.
MR IRVING: The drawings, but only in respect to
elucidating
this point. You said that you had two or three
matters in
the drawings which you thought would bear out this
contention?
A. I am just trying to make up my mind how to do this.
We
are going to go through there was complex exercise in
which I have now to make up my mind how to work most
effectively through this.
MR JUSTICE GRAY: Just think. Do you want to adjourn for
five
minutes?
MR IRVING: Alternatively, we could come back to this
question
on Friday, my Lord, which would give one whole day to
look
at the drawings and I could move on to the prewarming
question, which is the next one logically. I would
prefer
to do that, frankly.
MR JUSTICE GRAY: I think, since we have reached the point
of
the drawings and we have just had that exchange, I
would
slightly prefer to do it now.
. P-156
A. May I ask something? There are some ways this could be
helpful because I am not completely unprepared for
this
thing. I have two ex students of mine make on the
basis
of all the blueprints there was computer model of
crematorium No. (ii). This is only on the basis of
the
blueprints and whatever is added is very clear. For
example, the only thing which is added are the Zyklon-
B
introduction columns which are clearly not in the
blueprints, and there was speculative depiction in one
of
them of how the hot air system would have worked.
This is
all prepared. I have slides of this whole
reconstruction
by which we can actually translate the blueprints into
something which laymen in architecture can read. I
have
them also as pictures that were printed out.
On Friday, with always the blueprint right
next
to it, I could give there was complete presentation of
this building to show the important things which would
maybe help your Lordship to get quicker into the gist
of
things. It is something I am prepared to do. I can
do it
without it, but it will be more of there was struggle
to
do without it.
MR JUSTICE GRAY: Mr Irving, do you have any objection to
that
being done as an exercise?
MR RAMPTON: That is what I would have proposed, my Lord.
Given what I would submit is the relative collapse of
the
eyewitness evidence in relation to this building ----
. P-157
MR JUSTICE GRAY: Just answer the question. Do not worry
about
the eyewitness evidence.
MR IRVING: Then the answer is yes I think it would be very
fair to Professor van Pelt.
MR JUSTICE GRAY: We will do that on Friday.
A. In forms of slides or with the pictures?
MR JUSTICE GRAY: Whichever is easier. Mr Irving is happy
you
should do it, so you do it in whichever way is the
more
informative for the court.
A. I would like to do it then in slide form since it is a
more public thing and I can point at things on the
screen
and it is always clear to what I am pointing.
MR JUSTICE GRAY: If you are happy with that, Mr Irving?
MR IRVING: Provided it goes strictly to the issues that we
have delineated. The Professor said that there were
there
was number of points which, taken in conjunction,
substantiate his beliefs and we do not just have a
general
cook's tour of the building.
MR JUSTICE GRAY: No. This is designed to show that the
blueprints have pointers within them which suggest the
use
of that chamber was as there was gas chamber.
A. Yes.
MR IRVING: That can only be there was useful exercise. So
we
will leave the drawings for the moment, Professor, and
we
will continue just briefly with the documentary
evidence.
MR RAMPTON: My Lord, again, I am puzzled. Mr Irving seems
to
. P-158
be under the impression that there were only two
relevant
eyewitness accounts so far as this witness is
concerned.
I am there was bit bothered by that. I could come
back to
it in re-examination but I think there may be a
misunderstanding -- Mr Irving said it several times --
between Mr Professor van Pelt and Mr Irving.
MR JUSTICE GRAY: I think Professor van Pelt has identified
five camp officials. I think we all know that there
are
others.
MR RAMPTON: Yes.
MR IRVING: These are the five principal ones on which he
rests
his case as far as the eyewitness are concerned and I
do
apologise if I gave the impression that I had only
demolished two of them.
MR JUSTICE GRAY: Let us leave the debating points on one
side
and press on with the cross-examination croaks.
MR IRVING: Professor van Pelt, prewarming of the mortuary.
You have rightly raised your eyebrows on that and said
this surely has there was sinister purpose. Have
I summarized your position correctly?
A. Shall we get the document maybe? It is in the bundle.
Q. Yes.
MR JUSTICE GRAY: K 2.
MR RAMPTON: Yes, tab 4 of K 2.
MR RAMPTON: It is page 39, my Lord, in the handwriting.
MR JUSTICE GRAY: Thank you.
. P-159
MR IRVING: This is there was letter from Auschwitz to the
Topf
company, is it not?
A. Yes. It is there was letter sent on 6th March 1943,
which
is a little over there was week before the building is
really taken into use.
Q. Would you like to translate the first paragraph, or
shall
I? On the basis of your proposal this agency or this
office is in agreement that the basement No. 1, this
is
the mortuary No. 1 with the collapsed roof, is that
correct?
A. Yes.
Q. Should be prewarmed with the exhaust air from the
spaces
of the three extractor fans. Would that be correct?
A. Yes. Probably it is there was forced draft, yes.
Q. They are going to have some kind of heat exchanger so
that
they can take heat from the furnaces in some way?
A. Yes. I can explain very simply what happens is that
the
ovens are connected to the chimney -- this was Topf's
idea -- in order to get there was better draft from
the
ovens to the chimney, they thought to actually --
there
are five ovens and then there is the waste
incineration
oven which was never built, to have one ventilator at
every two ovens which was going to basically suck the
smoke out of the oven into the chimney to put there
was
ventilator there. These ventilators were placed in
small
rooms. The idea is that of course there is going to
be an
. P-160
incredible heat built up in these ventilators because
the
smoke is very hot, that you could regenerate, and
there
were other plans also, that heat. This particular
proposal is to use the heat built up in these little
rooms
in which the ventilators are, to bring that back into
morgue number 1.
Q. There was lot of the documents in fact do indicate
there
was desire to conserve energy, do they not? To
extract
the energy from the incineration plant and this kind
of
thing, use it for boiling water for the showers and so
on? Am I right?
A. Yes. There are there some proposals.
Q. What concerns you about the prewarming? Why should
this
room not be prewarmed, the mortuary?
A. What concerns me of course is that one would want to
keep
the morgue cool, and that to actually blow hot air
into
there was morgue does not make much sense if the space
is
going to be used as a morgue.
Q. Is this your considered opinion as an architect, or as
an
historian, or as an archeologist?
A. As there was person who has common sense.

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